GHS: 'The New Rules Are Better Rules'
Adapting to new chemical handling regulations for solvents.
Tom Tattersall is executive vice president and chief operating officer of MicroCare Corp., a supplier of fluids and tools used in precision cleaning, coating and lubricating. He spoke with CIRCUITS ASSEMBLY online about changes in the industry stemming from the new Globally Harmonized System for Hazard Communication standards being deployed by governments and agencies worldwide in 2015.
CA: The GHS standard has changed every company’s hazard communication programs, with the new regulations requiring standardization of safety data sheets, chemical labelling and the training of employees. How has MCC implemented this regulation, including the June 2015 deadline for labelling and Safety Data Sheet upgrades?
TT: The GHS safety standard is a regulatory milestone. It sets uniform standards in the way the world works with chemicals, handles them, ships them, stores them and labels them. MicroCare has spent the last two years learning about the new rules and adapting our product labels, warnings, safety data sheets and product specs to be in compliance. With more than 1,000 product labels and documents, this was a huge job, but we completed it on schedule, well before the mandated deadline to ensure we were ready to be able to distribute the products quickly and within the required guidelines.
CA: Why was this so hard?
TT: One of the problems, of course, is the “globally harmonized” standards are complicated documents which include enormous amounts of information. They have also not been adopted in a uniform manner globally; there are subtle but significant variations from the United Nations standards in many countries, and some of the local variations actually contradict each other.
Another problem is the rules keep evolving. Sometimes the regulations change even before we have finished implementing the previous changes – they’re a real moving target! These modifications make it a very complicated process, as producing labels and documents that are technically accurate, locally compliant and up-to-date is complex and expensive. But it’s what we do and it’s the right thing to do.
CA: The US Occupational Health and Safety Administration has made the first significant changes in product labelling and Safety Data Sheets in nearly 30 years. How have you addressed this?
TT: There can be no shortcuts when it comes to safety. At the core of the safety issue is getting the data right on the Safety Data Sheets and labels. But even more important is employee training.
It doesn’t make anyone safer to publish a new Safety Data Sheet if nobody understands what they’re reading. So going forward, safety training will be a perpetual task for companies.
But the new rules are better rules. The new GHS rules specify that safety data must be presented consistently in a defined format, with detailed content about toxicity, first aid, handling and such. Even the name of the document has changed. The old term, “material safety data sheet,” indicates a document that is not in compliance with the new rules.
To ensure everyone receives and understands the new information, the regulators have changed the name to “Safety Data Sheet.” Companies should now replace all their old MSDS sheets with the new-format SDS sheets. We’re sending them out to all our customers, as well as posting them on our website to make them easily accessible.
CA: So GHS compliance was fundamentally just a paperwork issue?
TT: Not at all. We had to review all of our chemical recipes and make sure they were tested, labelled and packaged according to GHS protocols. For example, the GHS regulations changed the process used to determine aerosol flammability. With the new GHS rules the definition of flammability for an aerosol product now is uniform in virtually all industrialized counties. This makes it easy for manufacturing engineers to compare products with confidence, and be comfortable that each has been tested and labelled to the same standard. The improved GHS regulations are an opportunity to standardize competitive claims and ensure worker health and safety is never compromised.
CA: How does this benefit end-user companies and the marketplace?
TT: When you whittle it all down, the basic benefit of GHS is this: Chemicals that are essentially the same, even if they are from different suppliers in different countries, should have similar labels and similar SDS content. We know there are at least 65 countries that have adopted GHS, and all hazardous chemicals in those 65 countries are now classified using the same basic GHS criteria. This significantly eases regulatory burdens for international companies who in the past had to comply with a global patchwork of hazard communication regulations. The GHS regulations are complex, but the overall benefit is a safer global workplace. GHS does result in a better trained and a better informed marketplace. This means less confusion for workers who handle those materials on a daily basis.
CA: What other regulations aﬀect your products, and how do you meet them?
TT: It would be hard to imagine a more closely regulated industry than the chemical industry. There are the GHS rules we just discussed. But the ingredients in our products are also regulated by anumber of laws, for example TSCA and The Clean Air Act, the FDA in the US, and REACH in Europe.
Many local governments also have their own rules, such as Proposition 65 and the smog-control policies in Southern California. There are also many restrictions on shipping products and waste disposal. We must also consider the non-regulatory requirements, such as self-restrictions imposed by insurance companies and users themselves, for example “no products that cause global warming.” It’s very complex, but the net benefit is a big leap forward for workers everywhere.
CA: How does the regulatory atmosphere aﬀect MCC and the products it brings to the market?
TT: As I said earlier, we operate in a global market with evolving regulations intended to improve worker safety and minimize environmental impact. The regulatory atmosphere weeds out obsolete technology and processes, which is beneficial overall. But it also presents business challenges.
However, all this change also creates an opportunity to work with our customers and learn their needs. We work with our vendors to develop newer products that are even safer, even more effective and more benign on the environment. In the next six months we will introduce seven totally new products that are GHS compliant, TSCA listed, REACH compatible, and highly effective in their functionality. This ability to adapt and evolve with new products is a key element of our business model.
CA: You work hard on environmental stewardship. How have you implemented this thought process in the electronics market, and how has it changed over the years?
TT: Stewardship is a word you hear often at MicroCare. Stewardship is our duty to help the customer protect themselves from dangers they cannot foresee. You see, we know more about these chemistries and cleaning processes than anybody. We cannot expect our customers to be as well-informed about the chemistries as are we; it’s simply not their expertise. They rely upon us to make the best possible recommendations, given their budgets and operating constraints. We cannot abuse that trust simply for the sake of making a sale.
Sure, we want the revenue as much as anybody. But when a customer asks if Chemical X would work, we stop and look at their whole cleaning process. Will it be safe to use that chemical? Is the machinery right for the chemistry? How’s the ventilation? Is there a risk of fire or overexposure to toxic chemicals? Will it be too expensive in the long run? How will they dispose of the chemistry once it’s used? Stewardship is an essential part of our business and a basic tenet to our success in the marketplace.
CA: Advances in solvent technology are leading to environmentally acceptable cleaning options – could you elaborate on this?
TT: The “chemical tool kit” with which we work is evolving rapidly. We are seeing more new ingredients and chemicals coming to the marketplace at a rapid pace. This is an exciting time for our company and our customers because new doors are opening, and new answers are arriving.
For example, one of the most exciting is a new low global warming molecule from Chemours (the old DuPont) called “Sion.” This product has excellent cleaning, toxicity and environmental properties that can easily replace traditional high-strength fluids such as trichloroethylene. We are awaiting its approval from the safety regulators. We anticipate bringing this to market during the third quarter of 2015. Companies and engineers should keep looking for flexible options; don’t get locked into one particular technology. The options are changing almost on a monthly basis.
CA: What do you see for the future in terms of regulations? How will your chemistries fit in?
TT: The future is bright for MicroCare and for critical cleaning as a whole. Customers are making more complex, high-performance products, and cleaning is an essential element in making those products work right. We are continually rolling out new products and anticipate more regulations coming in the future. Suppliers will need to continue to invest in people and processes to stay on top of the safety issue. We are committed to providing our customers with accurate and timely advice as we work together to meet cleaning needs and the highest environmental standards.